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The Philippine government has started development of a new National Anti-Money Laundering and Counter-Terrorism Financing Strategy (NACS) from 2026 to 2030. Key agencies of the government, headed by the AMLC, will work together in the creation of the new strategy, including determining timelines, providing technical assistance, and monitoring the implementation of the work plan of each participating agency. This is in relation to the country’s efforts to maintain its status outside the Financial Action Task Force (FATF) grey list after being removed from the list only last year.
New Strategy to Keep the Philippines Off the FATF Grey List
The new NACS is one of the most important aspects of the Philippines’ current efforts to maintain its status outside the FATF grey list, which had previously identified weaknesses in the country’s defenses against money laundering and terrorism financing. The new strategy was officially announced through the Official Gazette, which stated that the new strategy for 2026-2030 will be based on the previous reforms and will strengthen the weaknesses. The strategy will provide a framework for the country’s responses over the next 5 years, particularly in areas long considered sensitive, such as gaming and other cash-intensive businesses.
The aim of the new strategy is not only to keep the country off the grey list but also to show continuous improvements before the next formal review cycle by the FATF.
Agencies, GOCCs, and LGUs Tapped to Align Plans
Marcos has directed national government agencies, government-owned or controlled corporations (GOCCs), and local government units (LGUs) to actively support the AMLC in drafting and implementing the new strategy. That instruction extends to entities like PAGCOR, the state gaming regulator, which falls under the GOCC umbrella. The order makes clear that agency-level action plans tied to NACS 2026–2030 must match each institution’s resources and stay within existing laws and rules.
Heads of agencies are instructed to make sure their internal plans do not operate in isolation but instead form part of a coordinated national approach. LGUs, while only encouraged rather than mandated, are expected to play a supporting role, particularly where local risks or exposure have been identified.
Risk Assessment Points the Way for Reform
The Philippines has submitted its Third National Risk Assessment 2021-2024, which assesses risks related to money laundering and financing of terrorism and the proliferation of financing. The bottom line: a risk-based approach is necessary—enforce and prevent based on the actual level and nature of risk. These findings are expected to significantly influence the development of the new National Anti-Money Laundering/Counter-Terrorism Financing System (NACS).
The timing could not be more significant. In 2027, the FATF will again evaluate how well the Philippines has implemented its 2014 Recommendations pertaining to anti-money laundering and terrorism financing. Prior reviews revealed deficiencies in regulating the casino and junket businesses and failure to take adequate steps on Suspicious Transaction Reports filed by casinos. The 2026–2030 strategy will be judged, in part, on how it responds to those specific issues.
Preparing for 2027 FATF Review
With the next FATF review peering over the horizon just a year after the new strategy, the Philippines is working on a tight deadline. The NACS must provide a clear and concrete roadmap to enhance supervision, enhance reporting, and address vulnerabilities in financial services, gaming, and other specified non-financial sectors.
For agencies and government-owned or -controlled corporations such as PAGCOR, this means enhancing internal policies and procedures to conform with the national strategy and demonstrating concrete progress. For the AMLC, this means coordinating a wide range of stakeholders, monitoring compliance, and demonstrating that recommendations from the Third NRA and previous FATF reviews are being implemented in meaningful reform.
National Coordination at the Center of AML Push
The latest policy circular makes it clear that AML/CTF efforts are not the responsibility of one agency but rather a whole-of-government initiative. By placing the AMLC in the lead role to guide NACS 2026-2030 and encouraging agencies, GOCCs, and LGUs to align their strategies, the administration makes it clear that coordination will play a key role in the next phase of reform.
While the country has recovered from the prior threat of being grey-listed and will be facing another FATF review in 2027, the new NACS that has been developed serves both as a roadmap for the country moving forward and as evidence of the commitment of the Republic of the Philippines to AML/CTF Reform. In the coming months, it will be interesting to see how vigorously and successfully these strategies are implemented into actual activities in the high-risk sectors that have felt government scrutiny in the past.
Source: Inside Asian Gaming (IAG)
